FIN-009: On-Grounds or Off-Grounds Indirect Cost Rate ApplicationDate: 10/21/2016 Status: Final
The University has established guidelines to assist in complying with Title 2 Code of Federal Regulations Section 200 and applicable cost accounting standards for those individuals who prepare and submit proposals for sponsored activities on behalf of the University. To prevent over-charging sponsors, these guidelines provide a basis for determining whether an activity is considered to occur On-Grounds or Off-Grounds and thus the respective rate to apply.
It is the policy of the Commonwealth of Virginia and the University to recover full indirect costs on sponsored activities. This policy is consistently applied except where there are limitations imposed by the sponsor, where a sponsor has no formal policy on the reimbursement of indirect costs, or where the uniqueness of the project warrants exceptional action; an exception request process is available to address these situations.
Indirect Cost Rate:
The rate the University is authorized to charge Federal sponsors to cover indirect costs for sponsored activities. The rates are set based on location (On-Grounds/On-Campus or Off-Grounds/Off-Campus) and the type of activity (organized research, instruction, or other sponsored activity). Rates are applied as a percentage of the Modified Total Direct Costs supporting the sponsored activity. The Federal agency that sets the University’s indirect cost rates is the Department of Health and Human Services.
Modified Total Direct Costs (MTDC):
All direct salaries and wages, applicable fringe benefits, materials and supplies, services, travel, and up to the first $25,000 of each subaward (regardless of the period of performance of the subawards under the award). MTDC excludes equipment, capital expenditures, charges for patient care, rental costs, tuition remission, scholarships and fellowships, participant support costs, and the portion of each subaward in excess of $25,000.
Those costs incurred for a common or joint purpose benefitting more than one cost objective, and not readily assignable to the cost objectives specifically benefitted, without effort disproportionate to the results achieved. The term Facilities & Administrative (F & A) costs is synonymous with indirect costs.
The University’s approved indirect cost rate for sponsored activities on which >50% of professional effort will be conducted in or on land, buildings or other space not owned by the University (state agency 207 or state agency 246) where all operation and maintenance expenses are directly incurred by the cost objective specifically benefited or are initially incurred by a Revenue Generating Activity (recharge center/service center) and then allocated to the cost objectives specifically benefitted based on an allocation plan approved by the Office of Cost Analysis. Off-Grounds locations may be privately rented/leased, government-owned, or owned by another university.
The University’s approved indirect cost rate for sponsored activities on which >50% of professional effort is conducted in or on land, buildings or other space owned by the University (state agency 207 or state agency 246) and land, buildings or other space leased by the University where the operation and maintenance expenses are incurred by non-sponsored University funding sources, e.g., state or local award types, and cannot be readily and specifically assigned to a particular project or cost objective. For the purposes of this policy, On-Grounds locations do not include leased land, buildings or other space where all operation and maintenance expenses are initially incurred by a Revenue Generating Activity (recharge center/ service center) and then allocated to the projects or cost objectives specifically benefitted based on an allocation plan approved by the Office of Cost Analysis.
Work performed by key/senior personnel (e.g., faculty) on a specific sponsored activity.
Sponsored Program Activities:
Externally funded programs under which the University is obligated to perform a defined scope of work according to specific terms and conditions and within budgetary limitations. These programs are to be budgeted and accounted for separately from other activities. Sponsored activities include grants, contracts, cooperative agreements, clinical trial agreements, Intergovernmental Personnel Agreements and other awarding instruments supporting research, instruction, public service, and clinical trials.
The Financial Analysis group, under the direction of the Assistant Vice President for Financial Planning and Analysis, is responsible for developing the University’s indirect cost rate proposal in accordance with Federal regulations and for negotiating with the University’s cognizant Federal agency (Department of Health and Human Services) to establish approved rates.
Individuals who prepare and submit proposals for sponsored activities on behalf of the University must apply the appropriate approved indirect cost rate, i.e., either the On-Grounds Rate or the Off-Grounds Rate, based on where the majority of the professional effort supporting the sponsored activities will occur.
As stipulated in the University’s rate agreement, a federal proposal can only have one indirect cost rate for the University’s portion of the work, i.e., subcontractors are expected to apply their own negotiated indirect cost rate.
Grant and contract proposals requesting the use of an Off-Grounds rate must include a summary chart of all professional effort showing the amounts to be expended On-Grounds and Off-Grounds.
Exceptions to the application of the appropriate full indirect cost are contingent on establishment of one or more of the following conditions established by the University and approved by the State Department of Accounts:
- The academic merits of the program are exceptional;
- The Program is part of an unusually important instructional or service role within the overall mission of the University;
- Available funding is very limited; or
- The application of the full rate would result in an inequitable recovery as in the case of a conference or institute involving a short period of time.
Requests for deviations from the full rates must be submitted in writing. The request must include a justification for the exception and the amount of indirect cost recoveries that will be forgone. The request must obtain sequential approvals from the department chair, dean, and Senior Associate Vice President for Research. Proposals including a deviation from the appropriate full indirect cost rate must include documentation of the Senior Associate Vice President for Research’s approval at the time it is submitted to the Office of Sponsored Programs.